Page 28 - RBS GRG F Case Study
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that "some elements of this inappropriate treatment of
                 customers should also be considered systematic."  (23)



                 Between 2005 and 2013 RBS put 16,000 business

                 customers into its GRG division, telling many it was there

                 to help turn their fortunes around.


                 However, the FCA commented that the bank had instead

                 systematically put its interests ahead of its customers.


                 But, despite these serious failings and inappropriate
                 behaviour identified by the FCA, the regulator has limited

                 powers to punish RBS as it does not regulate the practice

                 of restructuring struggling businesses.


                 RBS responded by announcing that it would refund

                 complex management fees worth £400 million to small

                 and medium-sized enterprises (SMEs) that went through

                 its restructuring process.


                 McEwan said the bank is "very sorry" for what happened

                 to businesses that went through RBS' restructuring arm

                 between 2008 and 2013, and insisted that: "The culture,

                 structure and way RBS operates today is fundamentally

                 different from the period under review."


                 There are however, many questions for the bank and

                 regulator to answer such as:


                 “• Why has RBS so vehemently denied the allegations of
                 the Tomlinson Report when the bank was in possession


                 of the evidence at the time?
                 • Why were RBS’ ‘independent’ reviewers, Clifford Chance,
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